UKCA vs CE marking: which mark to use in Great Britain and Northern Ireland

The short answer for 2026

For most products covered by UK product regulations that mirror EU CE-marking legislation — electrical equipment, electromagnetic compatibility, radio equipment, toys, machinery, personal protective equipment, and others — you can place goods on the Great Britain market with the CE marking, the UKCA marking, or both. GOV.UK guidance states that the UK continues to recognise the CE marking alongside or in place of the UKCA marking, and gives no end date.

Northern Ireland is different. Under the Windsor Framework, relevant EU rules on manufactured goods apply there, so goods need the CE marking, or CE plus UKNI where a UK body carried out a mandatory third-party assessment. The UKCA marking on its own is not accepted in Northern Ireland. The EU market, as before, requires the CE marking for products whose EU legislation provides for it.

How CE recognition in Great Britain became open-ended

Recognition of CE marking in Great Britain was originally time-limited, and the end date was pushed back several times. The decisive steps were announcements in 2023 and 2024 followed by legislation that took effect in October 2024.

Which regulations the indefinite CE recognition covers

The August 2023 announcement listed 18 regulations owned by the Department for Business and Trade. If your product falls under one of these, CE marking based on the EU requirements and EU conformity assessment remains acceptable in Great Britain:

• Toys, pyrotechnics, and recreational craft and personal watercraft.
• Simple pressure vessels, pressure equipment, gas appliances, and aerosols.
• Electromagnetic compatibility, low voltage electrical equipment, and radio equipment.
• Non-automatic weighing instruments, measuring instruments, and measuring container bottles.
• Lifts, equipment for potentially explosive atmospheres (ATEX), and machinery.
• Personal protective equipment and equipment for use outdoors (noise emission).

Sectors with their own rules

The GOV.UK sector table published in March 2026 shows that open-ended CE recognition does not apply everywhere. These are the sectors to check first:

Northern Ireland, the Windsor Framework, and the UKNI mark

Under the Windsor Framework, relevant EU rules for manufactured goods apply in Northern Ireland. In practice that means EU product legislation, EU conformity assessment procedures, and the CE marking. The UKCA marking alone does not give access to the Northern Ireland market.

The UKNI marking exists for one situation: when the applicable EU legislation requires mandatory third-party conformity assessment and a UK body — a Northern Ireland notified body — carries it out for the Northern Ireland market. UKNI is never used alone; it always accompanies the CE marking. If an EU notified body carries out the assessment, the product carries CE only.

Qualifying Northern Ireland goods that carry CE, or CE plus UKNI, can be placed on the Great Britain market. Product safety law also differs: the EU General Product Safety Regulation (EU) 2023/988 applies directly in Northern Ireland from 13 December 2024, while in Great Britain the General Product Safety Regulations 2005 continue to apply.

Which marking for which market

Many businesses want one product configuration for the UK and the EU. For most regulated products that is possible with CE marking based on EU conformity assessment, provided no sector exception applies. The decision table summarizes the options:

Using the UKCA marking correctly

If you choose UKCA — because your conformity assessment was done by a UK approved body, or because you want to show UK conformity explicitly — the rules mirror CE marking. The UKCA marking must be at least 5 mm high unless sector legislation says otherwise, and it must be visible, legible, and indelible.

Under the Fast-Track UKCA approach, UKCA can be applied on the basis of recognised EU requirements and conformity assessment processes, which helps businesses that want UKCA without duplicating testing. Until 11pm on 31 December 2027 the UKCA marking may be placed on a label affixed to the product or on an accompanying document, rather than on the product itself.

UK declaration of conformity: required contents

A UKCA-marked product needs a UK declaration of conformity. It closely follows the EU model, but it refers to UK legislation (or recognised EU regulations) and UK designated standards. GOV.UK lists these elements:

• Name and full business address of the manufacturer or authorised representative.
• Product serial number, model, or type identification.
• A statement that the manufacturer takes full responsibility for compliance.
• Details of the approved body that carried out the conformity assessment, if applicable.
• The relevant legislation the product complies with — UK legislation or recognised EU regulations.
• References to the relevant designated (UK) or harmonised (EU) standards, including their dates, or other technical specifications.
• Name and signature of the person authorised to sign.
• Date of issue.
• Supplementary information, if applicable.

UK importer details and the labelling easement

Both manufacturers and importers must give their name, registered trade name or trade mark, and postal address on the product. Where that is not possible — for example because the product is too small — the details can go on the packaging or in an accompanying document.

There is an easement until 11pm on 31 December 2027: for goods imported from the EEA (and in some cases Switzerland), importer details may be given in an accompanying document or on the packaging instead of on the product. Plan label changes for products where the easement is the only reason the importer details are not on the item itself.

The declaration and technical documentation are typically kept for 10 years, counted from when each individual product is placed on the Great Britain market. Check the sector legislation for the exact period.

The Product Regulation and Metrology Act 2025

The Product Regulation and Metrology Act 2025 received Royal Assent on 21 July 2025. It is a framework Act: it gives ministers powers to make product regulations, including rules for online marketplaces, as well as metrology regulations and enforcement and information-sharing powers. Food, feed, medicines and medical devices, aircraft, military equipment, and other listed products are excluded.

The Act itself does not change which marking you use. The Office for Product Safety and Standards consulted from 31 March to 23 June 2026 on a new UK product safety framework to replace the General Product Safety Regulations 2005, including online marketplace duties. As of October 2026 the government was analysing feedback and no final regulations had been made, so watch for secondary legislation before relying on today’s position for long-term planning.

Practical checklist for UK market access

Before shipping a product line to the UK, work through these steps:

1. Confirm which UK regulations apply and whether the product falls into a sector with its own regime, such as medical devices, construction products, marine equipment, rail, drones, or batteries.
2. Decide your destination markets: Great Britain, Northern Ireland, the EU, or a combination.
3. Choose the marking: CE for most products across all three markets; UKCA if you rely on a UK approved body for Great Britain; CE plus UKNI only if a UK body performs mandatory third-party assessment for Northern Ireland.
4. Prepare the matching declarations — an EU declaration for CE, a UK declaration for UKCA — and keep the technical documentation behind them.
5. Check labels: manufacturer and importer name, trade name or mark, and postal address on the product, and whether the 31 December 2027 easement applies.
6. Record expiry dates for anything time-limited, such as CE acceptance for medical devices, and set reminders.
7. Monitor GOV.UK guidance and new regulations under the Product Regulation and Metrology Act 2025.